The plaintiff claimed that its copyright in the format/elements of a reality show to identify children with acting talent was infringed by the defendant who had also produced a show aimed at identifying talented children. The plaintiff produced a production bible which laid out the format of the show, its thematic concept, various elements of the show, qualities expected in a judge, host and so on to establish that it had come up with a unique ‘copyrightable’ work. However, the Bombay High Court in its judgement dated 4-4-2017 in the case Zee Entertainment Ltd v. Sony Picture Networks India held that though it may be possible to claim copyright in a production bible, the plaintiff could not establish how the skill or labour expended by it resulted in a novel sequencing of the event. in subjecting children to various tests, eliminating the less talented ones and rewarding the winners. Thus, the Court declined to grant the injunction sought by the plaintiff.
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Production bible of TV show without novel elements is not a copyrightable work
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